Salt Lake City’s rapid growth is expanding into areas affected by historic mining, where mine tailings—residual materials from ore processing—pose environmental and financial challenges. However, these tailings do not inherently preclude development; rather, they should be treated as specialized brownfields that can be safely redeveloped through informed due diligence and risk-based planning.
Understanding Mine Tailings in Salt Lake City’s Growth
Utah’s long mining history has left tailings spread across large areas, which were historically viewed as inert fill but now lie beneath or near expanding development corridors. These tailings are a common due diligence concern in real estate transactions, yet misconceptions about their impact can lead developers to overestimate remediation needs. Many tailings-affected sites can be redeveloped successfully using established environmental and engineering methods.
Mine Tailings as a Unique Brownfields Remediation Condition
Mine tailings qualify as brownfields—previously disturbed lands with environmental concerns—but differ from typical urban brownfields. Unlike discrete contamination sources, tailings are shallow, widespread, and usually contain elevated levels of metals such as arsenic, lead, cadmium, or mercury, spread uniformly across large areas. This lateral, shallow nature supports practical, risk-based solutions that focus on exposure management rather than full removal, protecting human health while controlling costs.
Regional Redevelopment Examples
Across the Salt Lake Valley, various redevelopment projects illustrate that mining legacies do not preclude development. Large master-planned communities, urban infill projects, former rail and industrial corridors, and river-adjacent developments have all successfully addressed historic environmental constraints by combining thorough planning, engineered controls, soil characterization, and exposure pathway evaluation. These examples demonstrate that early investigation and regulatory coordination enable routine and feasible brownfields redevelopment, including sites with mine tailings.
Due Diligence and Site Assessment
Effective redevelopment begins with comprehensive due diligence. Phase I Environmental Site Assessments identify historical mining or smelting activities through historical maps and records. If environmental concerns are found, Phase II investigations focus on soil metals characterization, the extent of impacted materials, and exposure pathways relevant to the proposed land use. These assessments inform feasibility assessments, cost estimation, site design, and purchase negotiations, reducing uncertainty and avoiding surprises later.
Utah’s Risk-Based Regulatory Framework
Utah employs a risk-based regulatory approach allowing tailored cleanup strategies based on site conditions and intended land use. Residential projects face stricter exposure standards than commercial or industrial uses. Common regulatory measures include engineered barriers (e.g., clean soil caps, pavement), construction soil management plans, and institutional controls that document site conditions and obligations. Voluntary cleanup programs offer regulatory certainty and liability protection, integrating environmental measures into project design rather than treating them as separate remedies.
Integrating Environmental Planning into Brownfields Remediation
Successful projects integrate environmental planning with civil engineering, grading, and construction sequencing. Tailings can be managed beneath building footprints, roads, or landscaped areas, acting as engineered caps. Excavated materials can sometimes be reused on-site under controlled conditions to reduce costs and traffic. Construction-phase soil management plans help contractors efficiently handle impacted soils, minimizing delays. This approach makes environmental considerations a manageable design parameter.
Managing Risk and Financial Considerations
Uncertainty is a major risk in brownfields redevelopment. Early characterization of tailings reduces uncertainty, enabling accurate cost modeling and contingency allocation. Additional risk-management tools include environmental insurance, negotiated purchase terms that reflect known conditions, and phased development strategies that spread cleanup costs over time. Sellers often price brownfields below market value due to perceived complexity, thereby giving knowledgeable developers a competitive advantage.
Importance for Salt Lake City’s Future Growth
Mine tailings are a distinctive redevelopment challenge in the Western U.S., with Salt Lake City central to this issue. As growth continues, the number of mining-impacted sites could increase. The key is not whether development can occur, but how thoughtfully and efficiently these sites are approached. Viewing mine tailings as brownfield opportunities rather than obstacles helps us unlock strategically located land while protecting health and the environment.
Conclusion: Key Takeaway
Mine tailings should not lead to project abandonment; instead, they should prompt early, informed inquiry, engagement of experienced professionals, and integration of environmental planning into development. Through due diligence and risk-based cleanup, tailings-impacted sites can support safe, vibrant, and profitable redevelopment that meets Salt Lake City’s growth goals and those of other states with similar conditions, such as Texas, New Mexico, and Nevada.
About the Author: Thomas (Tom) Gordon, EP, serves as a senior project manager with SCS Engineers in Salt Lake City and can be reached at SCS Engineers. He specializes in environmental due diligence, brownfields redevelopment, and risk-based cleanup strategies that support development projects across the region.
Additional Brownfields Remediation Resources:
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A recent examination by SCS Engineers Project Directors Evan Guignon, PE, and Michael Bradford, PE, into geosynthetic liner damage and repairs examined the permeability of geosynthetic liners used in waste containment systems. Their blog focuses on the significance of lined containment, the perception versus reality of liner permeability, liner installations, and liner repairs.
Importance of Lined Containment
Lined containment is crucial for managing solids, liquids, and gases in waste containment systems. Over the past 50 years, regulations such as CCR Title 27, Title 40 CFR, and RCRA (Subtitle D) have emphasized the need for effective containment.
Liner Permeability: Perception vs. Reality
The common perception is that geomembrane barriers are impermeable and that lined ponds are watertight. However, even a “perfect” liner will leak through diffusion. The leakage rate is influenced by the head over the liner, ranging from 1 to 8 gallons per acre per day for a standing head of 1 to 10 feet deep.
Minimizing Leaks: Liner Installations
Successful liner installations involve multiple stakeholders, including manufacturers, installers, design engineers, Construction Quality Assurance (CQA) engineers, and laboratories. Common defects and damages during installation include manufacturing defects (e.g., needle holes), installation errors, equipment damage, and issues with waste/material placement. CQA (Construction Quality Assurance) engineers play a vital role in minimizing these defects and ensuring the liner’s integrity.
Detecting and Managing Leaks
Single-lined facilities use groundwater or soil gas vapor monitoring wells to detect leaks. Dual-contained facilities use leak detection systems called pan lysimeters. The EPA Action Leakage Rate (ALR) recommends 1,000 gallons per acre per day for ponds and 100 gallons per acre per day for landfills. States can set their own ALR values based on the type and function of containment. If leaks exceed the ALR, inspections and repairs are performed to address liner containment.
Liner Repairs
When damage occurs to ponds or cells, repairs are necessary. Damage can be internal (e.g., wrinkles, creases) or external (e.g., rocks, operations, environmental factors). Long-term UV exposure, catastrophic events (e.g., fire or wildlife), and slope stability failures can also cause damage. Repair solutions for ponds and impoundments involve draining, cleaning, and replacing or repairing the liner. The process for cells includes exposing them, cleaning them, and repairing or replacing the liner.
Geosynthetic Liner Conclusion
The design, material manufacturing, installation, CQA services, lab testing, and leak/damage monitoring all contribute to the overall effectiveness of the containment system. CQA, with continuous monitoring and timely repairs, is essential to maintaining the integrity of these systems.
About the Authors:
Evan Guignon, PE has experience with semiannual reporting, exceedance tracking, and regulatory compliance related to environmental projects. He has training in AutoCAD Civil 3D Advanced Landfill Grading Applications and Plant 3D Modeling. Evan’s background includes stream restoration design planning and research involving cement sample preparation and testing according to ASTM standards. Mr. Guignon holds multiple state Professional Engineer licenses.
Michael Bradford, PE brings over 20 years of experience in civil engineering and project management, specializing in solid waste landfill and public works projects. His expertise includes landfill site planning, excavation and grading design, stormwater management, geosynthetic liner design, landfill gas collection and control systems, and leachate recovery system design. Mr. Bradford has managed large-scale landfill expansions and closure projects, including permitting and construction quality assurance, and holds multiple state Professional Engineer licenses as well as CQA/CQC certification for geosynthetic materials inspection. His work includes managing permit modifications and landfill expansions that extended facility life by decades, demonstrating his capability in regulatory compliance and technical leadership.
Evolving Geosynthetic Clay Liners and Coal Ash, Waste360, Eric Nelson of SCS and EREF Researcher Kuo Tian discuss polymer-modified Geosynthetic clay liners that can manage aggressive leachate and meet EPA’s requirements. The polymer-modified alternative system is a sustainable …
Practical Implications for Industrial and Solid Waste Facilities and the Real Estate Industry
Following the EPA’s announcements on PFAS/PFOS destruction and disposal since 2023 and the most recent Interim Guidance in April 2026, trends indicate widespread implications for industrial facilities, the real estate industry, and the solid waste and wastewater industries. PFAS controls and liability frameworks under CERCLA/Superfund and RCRA are tightening rather than rolling back, increasing compliance planning, monitoring, and litigation risk.
EPA finalized CERCLA hazardous substance designations for PFOA and PFOS (including salts and structural isomers) in April 2024; the rule took effect in July 2024 and is being defended by EPA amid ongoing D.C. Circuit litigation.
EPA is evaluating whether to designate seven additional PFAS as CERCLA hazardous substances (PFBS, PFHxS, PFNA, HFPO–DA/GenX, PFBA, PFHxA, and PFDA), following an April 2023 ANPRM.
For facilities and real estate transactions, the PFOA/PFOS CERCLA designations can affect Phase I ESA expectations, PRP determinations, closed-site reopeners, and release reporting; releases of ≥1 pound in 24 hours trigger CERCLA/EPCRA reporting obligations.
EPA proposed listing nine PFAS as RCRA hazardous constituents in February 2024 and intends to finalize the rule in 2026, which could expand corrective action obligations for generators and TSDFs with relevant solid waste management units.
In April 2026, EPA updated its interim guidance on PFAS/PFOS destruction and disposal (Version 2, April 2024), identifying options with lower potential for environmental release, such as permitted Subtitle C hazardous waste landfills, permitted hazardous waste combustors, and permitted Class I injection wells. SCS Engineers has prepared an SCS Technical Bulletin to walk our clients through the announcements and discuss the impact and trends.
The U.S. Environmental Protection Agency (USEPA) has issued guidance to simplify the Title V operating permit renewal process, emphasizing administrative efficiency while maintaining full compliance obligations. The guidance encourages focusing on changes rather than resubmitting unchanged information, but facilities must remain vigilant as renewals can reveal unresolved compliance issues.
Streamlined renewal process: The guidance permits the use of previously submitted materials, incorporation by reference, and directs agencies to concentrate on changes, without altering regulatory or compliance requirements.
Renewal as compliance check: Even if operations are unchanged, renewals prompt reassessment of assumptions, monitoring, and applicability, potentially affecting more than just the renewal itself.
Risks and consequences: Identified gaps during renewal can lead to notices of violation, permit modifications, increased monitoring, enforcement actions, and future scrutiny, often uncovering longstanding issues rather than new violations.
Common issues and affected industries: Problems frequently arise from outdated potential to emit assumptions, monitoring methods, operational changes, or unvalidated permit bases, impacting sectors such as manufacturing, printing, power generation, food production, petroleum, and data centers.
Leslie’s rare combination of technical expertise, client relationship skills, and community involvement is remarkable for a Young Professional, even by today’s standards. Late last week, Leslie gratefully accepted a 40 Under 40 award from the American Academy of Environmental Engineers and Scientists (AAEES). We hope you enjoy learning a little more about our colleague at SCS Engineers.
As a Project Manager at SCS Engineers, Leslie leads remediation and redevelopment of complex contaminated sites in South Florida and was an early contributor to PFAS investigation procedures. Her early career projects included national Superfund site research and large-scale investigations of military sites. She also demonstrates her commitment to community and professional development through mentoring and volunteering.
Leslie Smith exemplifies the qualities celebrated by the AAEES 40 Under 40 program and SCS values. She has multiple publications under her belt and holds a B.S. in Civil and Environmental Engineering and an M.S. in Civil Engineering (Environmental Engineering) from Florida State University, as well as a Ph.D. in Civil Engineering (Environmental Engineering) from Louisiana State University.
Technical and Business Accomplishments
Leslie has built strong, enduring relationships with major residential and commercial land developers in South Florida, earning trust through straightforward communication and effective project management of large-scale remediation projects, balancing schedules and budgets.
She manages complex environmental assessments and remediation for large-scale redevelopment projects, including a 100+ acre former golf course and agricultural properties, successfully engineering on-site reuse of contaminated soil to reduce costs and environmental impact, thereby converting contaminated sites into residential communities.
Her doctoral research involved pioneering bioremediation at scale by correlating pilot systems with full-scale Superfund site operations, characterizing microbial communities via DNA sequencing, and validating remediation efficacy—work that resulted in peer-reviewed publications and presentations.
Early in her career, Leslie was part of a large-scale site investigation at a former Cold War missile launch complex in Wyoming, addressing severe TCE contamination across a plume spanning 20,000 acres. This project shaped Leslie’s approach to contamination management.
Leslie continues to contribute her expertise to the evolving field of PFAS contamination by assisting Florida’s Department of Environmental Protection in developing Standard Operating Procedures, conducting field assessments at fire training facilities, influencing state regulatory responses, and publishing in industry publications.
Community & Civic Involvement
Water Matters Day
Leslie regularly volunteers at Deck the Halls, a community event that supports children in foster care by decorating homes for the holidays.
She also participates in Water Matters Day in Broward County, promoting water conservation through educational booths, giveaways, and activities, and in Baynanza, Miami-Dade’s celebration and cleanup of Biscayne Bay, contributing to ecological restoration efforts.
She mentors K–12 and undergraduate students in STEM education, fostering curiosity and supporting growth through lectures and research guidance. She supports affordable housing initiatives through volunteering with the Appalachian Service Project, Habitat for Humanity, and Bike & Build, aiding families with home repairs and raising awareness of housing issues.
We are extraordinarily proud of Leslie for her professional achievements and community activism, as well as our other Young Professionals at SCS, who are using their education, certifications, and expertise to demonstrate that business and protecting our environment go hand in hand.
Today’s blog discusses the challenges and opportunities related to the redevelopment of land with idle or abandoned oil wells, also known as orphan wells. At least twenty-eight states currently face the same challenge and are spending federal funds on abandoned well remediation. The majority of the orphan wells are in the Gulf Coast area, including Texas, New Mexico, Oklahoma, and Louisiana. Also, the Northern Appalachia area, including Pennsylvania, Ohio, West Virginia, New York, and Kentucky, has thousands of wells. For this blog, we focus on California, a state with unique regulatory and land-use considerations.
Due Diligence First
We stress that proximity to sensitive sites isn’t the same as risk, and we support informed, technical assessments and regulatory oversight to enable safe redevelopment, especially in urban areas. When first drilled, many wells in California were likely not in urban areas, but over time, the growth of our cities and towns has shown that they can literally now be in property owners’ backyards as well as underneath residential and commercial buildings. Conducting thorough technical evaluations is essential for safe redevelopment practices.
Understanding Risks and Redevelopment Potential
Let’s address the common misconception that proximity to orphan oil wells near schools, parks, and homes inherently means danger. We understand your concerns and will address public health and environmental risks to ensure redevelopment proceeds safely. Redeveloping former oil-field lands, often vacant lots in urban areas, can boost property values and economic growth while protecting our health through proper well-impact mitigation and access to funding sources.
Addressing Orphan Oil Wells in California (Onshore)
California faces a unique challenge: thousands of legacy oil wells are scattered across urban and rural areas. The key issue is not just their location but how these wells are evaluated, managed, and regulated amid changing land uses. The majority of oil wells are located in the Southern California counties of Kern, Los Angeles, Orange, Santa Barbara, and Ventura due to geological factors. The counties of San Bernardino, San Diego, and Riverside have the fewest number of oil wells.
California Senate Bill 1137 (2022) established health protection zones around sensitive land uses near idle or abandoned wells, reflecting California’s urban growth since many wells were drilled. Proper risk mitigation requires technical clarity on well drilling and conditions, beyond simple location maps.
Regulatory oversight is conducted by the California Geologic Energy Management Division (CalGEM), which enforces stringent standards (California Public Resources Code [PRC] § 3208.1) for well access, integrity, and abandonment. CalGEM can mandate “re-abandonment” to modern standards that emphasize cement isolation, groundwater protection, and long-term monitoring to ensure redevelopment safety. Recognizing these specific regulations helps stakeholders understand the regulatory environment guiding land reuse projects.
Integrating Development and Health Safely
There are successful redevelopment projects in areas with high numbers of abandoned wells, such as Pacific City in Huntington Beach and the 2nd & PCH shopping center in Long Beach. These projects rely on qualified petroleum engineers and geologists who conduct thorough due diligence, including review of historical well records, field verification, vapor and methane assessments, and coordination with regulators.
Where necessary, Vapor Intrusion Mitigation Systems (VIMS) are integrated into project designs to prevent toxic vapors from contaminated soil or groundwater from entering buildings, protecting indoor air quality. Early identification and mitigation during due diligence help protect public health and control costs.
Differentiating Well Types and Funding Mechanisms
Not all idle or orphan wells are the same. You can use CalGEM’s Well Finder to distinguish between well types and operators. Many wells remain under active operators with Idle Well Management Plans and bonding requirements. Truly orphaned wells mean that no responsible operator remains, but California can proceed with state plugging and sealing. These are addressed through a state-run orphan well program with four funding sources:
Ensuring Effective Regulatory Enforcement and Collaboration
The Center for Biological Diversity’s 2026 report highlighted sensitive land-use areas near wells, raising public awareness. However, effective risk reduction depends on collaboration among regulators, landowners, developers, environmental advocates, and local governments, fostering trust and shared responsibility.
CalGEM recommends engaging qualified petroleum professionals who are familiar with California’s regulatory framework for the safe, responsible evaluation of legacy wells. Early, transparent evaluations integrated into land-use planning protect communities and enable urban infill and redevelopment without undue fear or delay.
Finding the Appropriate Support to Minimize Risk
We recommend finding an engineering firm, preferably with a background in the petroleum industry and a successful track record in remediating brownfields and performing highly structured due diligence. The engineer will likely rely on the expertise of a geologist or hydrogeologist, depending on the location. You’ll want more than a due diligence consultant; you’ll need, in states like California, a California-licensed professional petroleum engineer (PE) and a California-licensed professional geologist (PG) as well. Assessing risks is complex. Firms like SCS Engineers provide the expertise to evaluate the land, complete the plug-and-abandonment process for the wells, and make properties valuable, sustainable, and useful again.
Author: Senior Project Manager and Geoscientist Tim Rathmann. Confer with Tim or an expert in your area at SCS Engineers, or reach Tim on LinkedIn.
This educational webinar explores how critical pressure informs the definition and refinement of a carbon sequestration project’s Area of Review (AoR) under the Class VI permitting framework. The SCS experts explain why some developers are re-evaluating AoR assumptions, how injection-driven pressure propagation can dominate AoR extent, and why project-specific geology (including fluid salinity and basin structure) can make simplified approaches overly conservative, rather than safer.
In this 17-minute session, we compare calculation approaches (Methods 2, 2A, and 3) and emphasize that early, iterative AoR work can reduce regulatory, cost, and public-trust risks.
AoR must account for both plume extent and pressure effects: Beyond the supercritical CO2 plume, pressurization and project critical pressure determine where fluids could migrate upward through improperly plugged/abandoned wells and potentially endanger underground sources of drinking water (USDWs).
Pressure front propagation is often the controlling factor: Pressure can propagate faster and farther than the mobile plume, and may be altered by geologic structures (e.g., faults).
Fluid salinity and density matter: Higher salinity increases fluid density and generally requires more induced pressure to drive vertical migration; real-world salinity profiles can be non-linear and project-specific.
Method selection depends on data and realism: Method 2 is simple but can yield unrealistic outcomes (e.g., zero/negative critical pressure). Method 2A uses a more detailed equation-of-state approach. Method 3 incorporates risk-based computational modeling of flow through a hypothetical, poorly-plugged well and can better handle complex cases.
Timing and iteration reduce downstream costs: Investing early and periodically re-evaluating AOR assumptions improves defensibility and can avoid costly changes after permitting.
Transparency supports outreach: The AoR process and re-evaluations (including public comment opportunities) can be communicated in plain language to build public confidence in drinking water protection.
Why You’ll Want to Join Our Carbon Sequestration Webinar Series
Carbon capture and sequestration (CCS) is rapidly transforming the way carbon emissions are reduced. In regions with heavy manufacturing and fossil-fuel power plants, CCS could be essential to sustain operations while managing emissions. Louisiana, Wyoming, West Virginia, North Dakota, Arizona, and Texas have secured Class VI primacy, accelerating the permitting process and opening the door for more CCS deployment. “We’re at a pivotal moment, and states aren’t hesitating to dive in,” says Stephanie Hill, national expert in carbon sequestration and deep well injection at SCS Engineers.
Stephanie advises interested parties to pay attention to CCS trends, which shape staff hiring, Class VI permit processing, and the modeling and monitoring required to support long-term project success.
As leaders in CCS, SCS Engineers has spent over a decade tracking technology advances and regulatory shifts. Now, we’re inviting you to join our free webinar series, where our team will break down the top five CCS trends shaping the future and what they mean for your organization. Whether you’re a state regulator, policymaker, utility manager, or industry executive, these carbon sequestration sessions will equip you with the knowledge to make informed, confident decisions in this rapidly evolving landscape. Here’s a sneak peek at what you’ll learn:
Trend 1: Using Advanced Critical Pressure Modeling to Shrink the Area of Review
Securing a Class VI well permit for CCS hinges on accurately defining the Area of Review (AoR), the underground zone where injected CO2 might impact drinking water sources. The traditional approach relies on a simplified, conservative pressure calculation. But this method can overestimate the AoR by 50 to 100 square miles, inflating project costs, pore‑space needs, monitoring requirements, and stakeholder engagement footprints.
“There’s a better way,” explains Dr. Charles Hostetler, senior project advisor and modeling SME at SCS Engineers. Our advanced critical pressure model tracks the evolution of brine pressures. The result is a more precise and realistic AoR.”
Trend 2: Accounting for Project Interference
Depending on geologic conditions, the pressure front created by CCS deep-well injection can influence conditions well beyond the CO2 plume boundary. With these forces at work, multiple injection projects within the same hydraulically connected reservoir can lead to overlapping pressure fields in the pore space, which could increase the AoR and the risk of CO2-brine migration into the USDW.
As use of CCS deep well injection grows, so does the challenge of accounting for pressures associated with Class I, II, and VI wells in the same region, including those installed or discovered after the AoR was first determined.
SCS Engineers has a plan for that. “When you design your model, think of the bigger picture,” says Charles. “A large, dynamic model allows integration of CO2 and pressure data from neighboring wells to predict potential influence on the AoR.”
Trend 3: Supplemental Permitting: Endangered Species Act (ESA)
Under the National Environmental Policy Act (NEPA), a regulatory authority must account for both direct and indirect impacts of Class VI projects. But it is challenging to determine how a project located 3,000 feet below ground might affect the habitat and populations of animals and plants above ground.
SCS Engineers is meeting that challenge by evaluating the relationship between deep subsurface CO2 injection and reasonably certain surface impacts.
“This evaluation will help standardize Class VI operations and species interactions, streamline and accelerate the review process, and develop direct links between projects, impacts, and mitigation,” says Charles.
As CCS activity grows, ESA and NEPA supplemental permitting is emerging as a critical component of project readiness.
Trend 4: Representing Well Corrosion in Modeling
Localized and uniform corrosion of the injection well could create potential leakage pathways for the CO2 plume. Applicants rely on corrosion modeling to anticipate when and where well materials may begin to degrade and to select compatible construction materials for the well.
“The drawback is that model predictions only go so far,” says Stephanie. “That’s why we turn to real-world data for AoR models.”
Working with a metallurgy lab, SCS Engineers obtained a forensic analysis of a real-world tubing failure that was predicted to withstand anticipated conditions. This insight helps account for model uncertainty, which could prevent tubing failure and the incurred costs of operational downtime and tubing replacement.
As more Class VI wells come online, data‑driven well integrity modeling is becoming an essential protective measure.
Trend 5: Integrative Monitoring for AoR Re-evaluation
Compliance with CCS regulations requires monitoring the CO2 plume spread and recalibrating the AoR every 5 years. “Integrated monitoring programs that use multiple methods are trending,” says Tara Gross, project advisor on the SCS Deep Well Initiative Team.
Early baseline data lay the foundation for monitoring and defining how AoR models are recalibrated going forward. Data gathered during pre-injection testing, such as well integrity and seismic, groundwater, surface, and subsurface conditions, are essential to support time-based comparisons, identify subtle subsurface changes, and track plume behavior over time.
Innovate with SCS Engineers
Join Stephanie, Charles, Tara, and other SCS national experts in upcoming webinars to stay ahead of industry trends and avoid costly surprises as CCS projects move from concept to execution!
The future of sustainable agriculture is taking shape on 400 dairy, poultry, hog, and beef farms across the U.S. Farmers from California to Massachusetts are integrating anaerobic digestion into their waste management practices to slash emissions and generate biogas for on-farm energy savings and revenue streams. Their impact is nothing to cluck at. Collectively, these farms reduced greenhouse gas emissions by 14.8 million metric tons of CO2 equivalent, and generated the equivalent of 3.29 million MWh of electricity.
“On-farm anaerobic digestion is becoming a more common component of the U.S. livestock model,” says Dr. Erik Anderson, Senior Project Manager and National Expert on Anaerobic Digestion at SCS Engineers. “Farmers use covered lagoons to sustainably manage waste, optimize their operations, and monetize waste streams.”
In the U.S., 43% of livestock farms with anaerobic digestion use covered lagoons as their digesters because lagoons are common and already facilitate biological decomposition. While a passive lagoon digester is a good low-cost option, its performance can be as fickle as the weather.
“Most passive lagoons only achieve about 60% of a material’s potential, sometimes lower,” says Erik.
Focusing on five elements, SCS’s hybrid approach, led by Erik, controls system conditions to boost biogas production and system efficiency. “A well-designed hybrid system closes the performance gap without overbuilding.”
Feedback and Control Loops
Digesters give “warning signs” that microbial conditions are imbalanced, such as changes in alkalinity, pH, volatile fatty acid, chemical oxygen demand, and overall methane production and concentrations in the biogas. Automated feedback systems read these warning signs and monitor essential parameters. “Real-time data enables active management to resolve problems quickly,” Erik says, “It is the rooster that wakes us up.”
Insulation and Heating
Many passive lagoons suffer from seasonality. When digester temperatures dip below 68°F, microbial activity slows significantly. Erik’s cure for these winter blues includes an insulated floating cover and an insulated lagoon bottom (typically made of reinforced or high-density polyethylene or clay-lined) that protects against the season’s colder temperatures.
“Insulation is only useful if there is heat to retain. If cost-effective, pre-heating lagoon waste would be the first design consideration…and it is often the most impactful,” says Erik.
Energy recovery systems that preheat the incoming lagoon feed are smart additions to new builds and retrofits. These systems either recover waste heat produced onsite through daily operations or economize the heat in the final effluent stream to cool and heat the two streams simultaneously.
Mixing
Passive lagoons do not typically incorporate mixing, often resulting in the accumulation of solids at the bottom and/or “fat” caps that form along the lagoon surface. SCS’s hybrid design incorporates mixing (and heating) and/or zone recirculation in either the staging tank or in the first lagoon of a two-lagoon system to create a homogenous flow and avoid microbial dead zones. This design also tolerates more total solids, generating more biogas.
“Mixing helps break down materials faster and transfers heat evenly throughout the system,” says Erik. “Properly designed mixing helps create a stable environment, which reduces the impacts of environmental changes, so microbes can thrive, improving digestion rates.”
Organic Loading Rates
How much volatile solids are fed into the digester is like Goldilocks trying porridge: it’s best when it’s just right. “Many slurry streams are too dilute, and given the sheer size of the digester, it could handle more material than it’s being fed,” Erik says. “I see that as leaving money on the table.”
While commercial digesters can run the design gamut from covered lagoons to high-solids and “dry” digesters, the nature of the project will determine the best option. It may be possible to take on higher concentrations of organic waste after evaluating project goals, mixing, material staging, feed control, and other parameters.
A hybrid design optimizes the build to the system’s upper limit, the sweet spot of maximum biogas production for the smallest footprint and the lowest price tag. Testing the effluent would reveal how much organic loading the system can accept, and thus, how much biogas it can optimally produce.
“If a system has capacity, it can take on more waste products to make more biogas and increase revenue,” says Erik.
Sustainable Energy Use
With minor adjustments, such as removing particulate and contaminants like H2S, biogas can be burned in onsite boilers to heat buildings, equipment, or the incoming digester slurry. Depending on the farm’s size and design, biogas can be converted into electricity for on-site or grid use via a combined heat and power plant, or purified to become renewable natural gas. Erik’s hybrid design is flexible to accommodate all energy generation pathways and goals.
“Mainly, the hybrid design encourages sustainable energy use,” says Erik. “Why not leverage our waste material and use the lagoon digester and onsite waste heat to its full potential? We have the opportunity to reduce farm costs and increase sustainability for the greater good.”
Meet Dr. Erik Anderson at the International Biomass Conference and Expo. Dr. Anderson will be on a panel session discussing hybrid anaerobic digestion entitled “Data Driven Strategies for High Performance Biogas Systems” on Wednesday, April 1 (1:00 pm – 2:30 pm).
As biogas and RNG projects scale, data-driven decision-making is becoming essential to maximizing performance, reliability, and returns. This session explores how operators are using high-quality data, advanced analytics, and AI-enabled tools to optimize anaerobic digestion, improve productivity, and reduce operating costs. The panelists examine practical applications ranging from real-time process monitoring and AI-enhanced operations to chemistry-based optimization and hybrid reactor design, offering actionable insights into how data and technology can unlock higher efficiency and resilience across modern biogas systems.
For decades, energy efficiency policies focused primarily on new construction. Existing buildings (especially older buildings) account for a large share of greenhouse gas emissions in the urban setting. Building Performance Standards (BPS) are state- and locally driven regulations that require owners of existing buildings to meet measurable energy or emissions performance targets over time—not just report data, but also achieve energy-efficiency objectives.
Since 2019, BPS policies have expanded rapidly across the United States, as shown in the map above (Courtesy of IMT). What began as voluntary benchmarking programs has evolved into mandatory, enforceable requirements with escalating targets and financial penalties for non‑compliance. More than 50 U.S. cities and several states have now adopted or committed to BPS policies, fundamentally changing the risk profile of owning and operating commercial real estate.
For building owners—especially those with portfolios spanning multiple jurisdictions—the challenge is clear: how do you comply without overspending, disrupting operations, or getting caught off guard by penalties and rushed retrofits?
What Are Building Performance Standards—and Where Do They Apply?
Building Performance Standards set minimum performance thresholds for energy use or greenhouse gas emissions. These thresholds typically tighten over time, pushing buildings toward deep efficiency improvements and, in many cases, long‑term decarbonization goals.
Today, BPS requirements exist at both the state and municipal levels, including:
Statewide mandates in Washington, Colorado, Maryland, and Oregon
Major municipal programs such as New York City (Local Law 97), Boston (BERDO 2.0), Washington D.C. (BEPS), Seattle, St. Louis, and Montgomery County, MD
Emerging adoption in smaller cities, signaling that BPS is no longer just a “big city” issue
The key takeaway for owners is simple: BPS policies are becoming the baseline expectation for building performance nationwide, not an exception.
What Is Required of a Building Owner?
While details vary by jurisdiction, most BPS programs require owners to:
Benchmark and report annual energy use
Meet specific energy use intensity (EUI) or emissions targets by defined compliance years
Implement corrective actions or improvement plans if targets are missed
3rd Party Certification
Failure to comply is no longer symbolic. Penalties are real and material, often including:
Fines based on excess emissions or energy use (e.g., dollars per metric ton of CO₂ or per kBtu over the limit)
Escalating penalties for repeated non‑compliance
Increased scrutiny, reporting requirements, and public disclosure
For large buildings or portfolios, these fines can quickly reach six or seven figures annually, turning energy performance into a balance‑sheet issue—not just a sustainability goal.
Competitive Advantage From Regulatory Burden
Forward‑thinking owners are reframing BPS from a compliance obligation into a strategic asset—those who act early gain flexibility, optionality, and financial upside. Key benefits include:
Lower Operating Costs
Targeted HVAC, lighting, controls, and envelope improvements routinely deliver 15–30% annual energy savings, reduce maintenance, and improve system reliability.
Stronger Asset Value
High‑performance buildings command:
Higher rents
Lower vacancy rates
Greater appeal to institutional investors and ESG‑driven capital
Risk Mitigation
Early action avoids:
Costly, last‑minute retrofits
Budget‑breaking fines
Disruption to tenants and operations
Health, Comfort, and Productivity
Improved ventilation, moisture control, and thermal comfort reduce absenteeism and enhance occupant performance—often the largest “hidden” financial upside for commercial tenants.
What This Means for Portfolio Managers
For owners and asset managers with buildings across multiple BPS jurisdictions, the challenge isn’t just compliance—it’s coordination.
A fragmented, city‑by‑city response leads to:
Inconsistent capital planning
Missed incentives
Higher lifecycle costs
A portfolio‑level strategy, on the other hand, allows owners to:
Prioritize buildings with the highest financial and regulatory risk
Sequence upgrades to align with capital cycles
Standardize solutions across markets
Maximize incentives and tax benefits
This is where experienced advisors add the most value—helping owners see the full portfolio picture, not just the next deadline.
How Building Owners Can Capitalize on BPS Requirements
Successful owners are taking a phased, data‑driven approach:
Portfolio screening to identify high‑risk and high‑opportunity assets
Targeted audits and retro‑commissioning (RCx) to capture low‑cost, fast‑payback savings—often under two years and growing with increasing energy costs
Improved ROI with energy cost increases across the country
Capital planning aligned with incentives, not rushed compliance
Long‑term roadmaps that anticipate future BPS tightening, not just today’s targets
Many jurisdictions now support this approach through Building Performance Hubs, utility programs, and technical assistance to lower upfront costs and reduce execution risk.
Funding the Path to Compliance
Compliance does not have to mean self‑funding every upgrade. Owners can leverage:
Section 179D tax deductions (up to $5.81 per square foot for qualifying projects)
Federal and state grants and rebates
C‑PACE financing, enabling 100% upfront funding repaid through property taxes
Green bank financing for complex efficiency and decarbonization projects
When coordinated correctly, these tools can significantly reduce—or even eliminate—the net cost of compliance.
Conclusion: The Cost of Waiting Is Higher Than the Cost of Acting
Building Performance Standards mark a permanent shift from voluntary sustainability to mandatory performance. For building owners, the question is no longer if action is required, but how and when.
Owners who act early gain control over costs, timelines, and outcomes. Those who delay risk fines, rushed decisions, and stranded assets. In a market where regulations are tightening and capital is increasingly performance‑driven, energy performance is now a core business strategy.
The smartest owners aren’t just complying, they’re using BPS as a lever to protect asset value, improve cash flow, and future‑proof their portfolios.
Look for an independent engineering consultant such as SCS Engineers with no financial interest in equipment sales, construction, or energy performance contracts. Your consultant’s expertise and vendor agnosticism provide objective, more valuable recommendations to owners selecting implementation strategies. Find a qualified engineering consultant near you.
To learn more about running facilities more efficiently and maximizing energy and water conservation, please visit our Facility Energy Management page.
About our Author:Doug Latulippe is a Project Director and one of our National Experts on Energy Management. He is responsible for work related to SCS’s air quality, greenhouse gas (GHG), and sustainability initiatives for public and private commercial businesses, industrial facility owners, real estate clients, utilities, and renewable energy project developers. Reach out to Doug on LinkedIn.
Doug’s experience includes managing energy portfolios, including capital and operating budget development, power generation, demand-side project and program development, bill management and reporting, and utility incentive program management. He also performed energy audits and GHG reporting for Fortune 500 companies.
As part of his power generation experience, he patented a solid-fuel gasification system designed for environmental mitigation and pollution control. The USEPA has recognized Doug for his extensive work with the ENERGY STAR program.
Doug is speaking at the A&WMA conference, Data Center Insights and Innovation, on Tuesday, March 24, 2026. Check out his session with David Greene at 11:40 am – 12:00 pm entitled The Data Center and Its Critical Role for Sustainability.
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These funds are specifically for California to support safe plugging and abandonment of orphan wells. (Source: 
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About our Author: Doug Latulippe is a Project Director and one of our National Experts on Energy Management. He is responsible for work related to SCS’s air quality, greenhouse gas (GHG), and sustainability initiatives for public and private commercial businesses, industrial facility owners, real estate clients, utilities, and renewable energy project developers. Reach out to 
